Gillette v. Uber Technologies,Inc.

Filing 52

STIPULATION AND ORDER re 51 STIPULATION WITH PROPOSED ORDER TO CONFIRM DEFENDANTS' TIME TO FILE RESPONSIVE PLEADING filed by Uber Technologies,Inc.. Signed by Judge Edward M. Chen on 6/18/15. (bpf, COURT STAFF) (Filed on 6/18/2015)

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JOHN C. FISH, Jr., Bar No. 160620
[e-mail]
ROD M. FLIEGEL, Bar No. 168289
[e-mail]
ANDREW M. SPURCHISE, Bar No. 245998
[e-mail]
LITTLER MENDELSON, P.C.
650 California Street
20th Floor
San Francisco, California 94108.2693
Telephone:
415.433.1940
Facsimile:
415.399.8490
Attorneys for Defendants
UBER TECHNOLOGIES, INC. AND RASIER,
LLC

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN FRANCISCO DIVISION

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ABDUL KADIR MOHAMED,
individually and on behalf of all others
similarly-situated,
Plaintiff,

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v.
UBER TECHNOLOGIES, INC.; RASIER,
LLC; HIREASE, LLC; and DOES 1-50,
Defendant.

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LITTLER MENDELSON, P.C.
650 California Street
20th Floor
San Francisco, CA 94108.2693
415.433.1940

Case No. 3:14-cv-05200-EMC
Case No. 3:14-cv-05241-EMC
STIPULATED REQUEST AND
[PROPOSED] ORDER TO CONFIRM
DEFENDANTS’ TIME TO FILE
RESPONSIVE PLEADING
Complaint Filed: November 24, 2014
Trial Date: None set.

RONALD GILLETTE, individually and on
behalf of all others similarly-situated,
Plaintiff,
v.
UBER TECHNOLOGIES, INC., a
California corporation, and DOES 1-20,
inclusive,
Defendant.
STIPULATED REQUEST AND [PROPOSED]
ORDER TO CONFIRM DEFS’ TIME TO
FILE RESPONSIVE PLEADING

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3:14-cv-05200-EMC
3:14-cv-05241-EMC

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Pursuant to Local Rule 6-2, Plaintiffs RONALD GILLETTE and ABDUL KADIR

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MOHAMED and Defendants UBER TECHNOLOGIES INC., RASIER, LLC and HIREASE, LLC

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(collectively, the “Parties”) hereby stipulate to confirm that the deadline for Defendants to respond

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to the complaints is July 9, 2015. This Stipulation is based on the following:

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1.

The Parties previously agreed in the Joint Case Management Conference Statement

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(Docket No. 34) that Defendants would have 30 days from the date of the Court’s ruling on

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Defendants’ motions to compel arbitration to respond to the complaints.

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arbitration.

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On June 9, 2015, the Court entered a ruling denying Defendants’ motions to compel

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Pursuant to the Parties’ agreement, and subject to this Court’s approval, Defendants

have until July 9, 2015 to respond to the complaints.

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4.

This request is not made by the Parties for purposes of unnecessary delay and no

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party will be prejudiced by the granting of this request. Defendant Uber Technologies, Inc. and

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Plaintiff Gillette previously stipulated to an extension of Defendant’s time to respond to the

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complaint. Defendants Uber Technologies, Inc. and Rasier, LLC and Plaintiff Mohamed previously

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stipulated to two extensions of Defendants’ time to respond to the complaint. Defendant Hirease,

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LLC and Plaintiff Mohamed previously stipulated to one extension of Hirease’s time to respond to

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the complaint.

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THEREFORE, the parties to this Stipulation hereby stipulate and respectfully request as

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follows: that the Court confirm the cutoff for Defendants to respond to the complaints as July 9,

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2015.

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LITTLER MENDELSON, P.C.
650 California Street
20th Floor
San Francisco, CA 94108.2693
415.433.1940

STIPULATED REQUEST AND [PROPOSED]
ORDER TO CONFIRM DEFS’ TIME TO
FILE RESPONSIVE PLEADING

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3:14-cv-05200-EMC
3:14-cv-05241-EMC

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Dated: June 18, 2015

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/s/ Andrew M. Spurchise
Andrew M. Spurchise
LITTLER MENDELSON, P.C.
Attorneys for Defendants Uber Technologies,
Inc. and Rasier, LLC

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Dated: June 18, 2015

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/s/Theodore Maya
Theodore Maya
AHDOOT & WOLFSON, PC
Attorneys for Plaintiff Abdul Kadir Mohamed

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Dated: June 18, 2015

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/s/ Laura L. Ho
Laura L. Ho
GOLDSTEIN, BORGEN, DARDARIAN &
HO
Attorneys for Plaintiff Ronald Gillette

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Dated: June 18, 2015

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/s/Mitchell J. Freedman
Paul K. Schrieffer
Mitchell J. Freedman
P.K. SCHRIEFFER LLP
Attorneys for Defendant Hirease, LLC

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Dated: June 18, 2015
/s/Sarah K. Hamilton____________________
Sarah K. Hamilton
SEYFARTH SHAW LLP
Attorneys for Defendant Hirease, LLC

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LITTLER MENDELSON, P.C.
650 California Street
20th Floor
San Francisco, CA 94108.2693
415.433.1940

STIPULATED REQUEST AND [PROPOSED]
ORDER TO CONFIRM DEFS’ TIME TO
FILE RESPONSIVE PLEADING

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3:14-cv-05200-EMC
3:14-cv-05241-EMC

SIGNATURE ATTESTATION

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In accordance with Civil Local Rule 5-1(i)(3), I attest that concurrence in the filing of this
document has been obtained from the signatories on this e-filed document.

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/s/ Andrew M. Spurchise
ANDREW M. SPURCHISE

Dated: June 18, 2015

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Dated: ______________, 2015

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___________________________________
HON. EDWARD M. CHEN
. Chen
dward M
Judge E

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June 18

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PURSUANT TO STIPULATION, IT IS SO ORDERED:

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UNIT
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Firmwide:134172089.1 073208.1047

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LITTLER MENDELSON, P.C.
650 California Street
20th Floor
San Francisco, CA 94108.2693
415.433.1940

STIPULATED REQUEST AND [PROPOSED]
ORDER TO CONFIRM DEFS’ TIME TO
FILE RESPONSIVE PLEADING

4.

3:14-cv-05200-EMC
3:14-cv-05241-EMC